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Czech Republic - Russia Tax Treaty (as amended by 2007 protocol) — Orbitax Tax Hub

Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.

ARTICLE 3

General Definitions

(1) For the purposes of this Convention, unless the context otherwise requires:

  • (a) the term "Czech Republic" means the territory of the Czech Republic over which, under Czech legislation and in accordance with international law, the sovereign rights of the Czech Republic may be exercised;
  • (b) the term "the Russian Federation (Russia)" when used in a geographical sense, means its territory, including internal waters and territorial sea, air space above them as well as the exclusive economic zone and continental shelf where the Russian Federation exercises sovereign rights and jurisdiction in conformity with federal and international law;
  • (c) the terms "a Contracting State" and "the other Contracting State" mean the Czech Republic or Russia as the context requires;
  • (d) the term "person" includes an individual, a company and any other body of persons;
  • (e) the term "company" means any body corporate or any entity which is treated as a body corporate for tax purposes;
  • (f) the terms "enterprise of a Contracting State" and "enterprise of the other Contracting State" mean respectively an enterprise carried on by a resident of a Contracting State and an enterprise carried on by a resident of the other Contracting State;
  • (g) the term "national" means:
    • (i) any individual possessing the nationality of a Contracting State;
    • (ii) any legal person, partnership or association deriving its status as such from the law in force in a Contracting State;
  • *(h) the term "international traffic" means any transport by a ship, boat or aircraft operated by a resident of a Contracting State, except when the ship, boat or aircraft is operated solely between places in the other Contracting State;
  • (i) the term "competent authority" means:
    • (i) in the case of the Czech Republic, the Minister of Finance or his authorized representative;
    • (ii) in the case of the Russian Federation, the Ministry of Finance or its authorized representative.

(2) As regards the application of the Convention by a Contracting State any term not defined therein shall, unless the context otherwise requires, have the meaning which it has under the law of that State concerning the taxes to which the Convention applies.